Tax & TRA

Tax Objection Tanzania: 30 Days, the Deposit and the TRA Decision

Cover: tax objection Tanzania, the 30-day limit, the one third deposit and the Commissioner General decision
How a Mainland taxpayer challenges a TRA assessment before it becomes final, and how ZRA objections differ in Zanzibar.
Direct answer

How do you object to a TRA tax assessment in Mainland Tanzania? Lodge a written notice of objection with the Commissioner General within 30 days of service, stating the grounds and attaching your evidence. Within the same 30 days, pay the greater of the tax not in dispute or one third of the assessed tax, unless TRA waives it. TRA then has six months to decide.

A tax objection in Tanzania is the first and compulsory step in challenging a TRA assessment or other tax decision. You cannot go straight to the Tax Revenue Appeals Board. The objection goes to the Commissioner General first, inside a short window, with money paid up front. Miss the window or the deposit, and the assessment becomes final.

This guide covers Mainland Tanzania under the Tax Administration Act, Cap. 438. Zanzibar taxes run by the Zanzibar Revenue Authority (ZRA) follow a separate Act, covered in its own section below.

What the law says

The objection rules sit in Part VIII of the Tax Administration Act, Cap. 438 R.E. 2023, as published by TRA. Part VIII is headed "Dispute resolution" and has four sections:

The Finance Bill, 2025, as published by the Ministry of Finance, proposed a new deemed-admission rule in section 62 and two provisos to section 63. TRA's own Taxes and Duties at a Glance 2025/2026 states the deemed-admission rule as current law. The EY analysis of the Finance Act, 2025 confirms both changes were enacted.

Older guides cite the Income Tax Act for objections. Those provisions were repealed when the Tax Administration Act came in. An income tax, VAT or excise dispute on the Mainland is a Tax Administration Act question.

Who should read this

If an audit is still open, read our guide to TRA audits and tax disputes first. A strong audit file makes a strong objection.

What counts as a tax decision you can object to?

Section 61 lets the Commissioner General make tax decisions on matters that directly affect a person. The common ones are:

Some matters are excluded. Practice notes, compounded offences, and matters settled by agreement or admission are not objectionable tax decisions. If you signed a settlement, the objection route is usually closed for that item.

Section 59 has a sting. The five-year limit on adjusted assessments does not apply in cases of fraud, wilful neglect or serious omission. An assessment issued after five years will often allege one of these, and the objection must then attack that finding as well.

How long do you have to object, and can you get more time?

Section 62(1) gives 30 days from the date the tax decision is served. Count from service, not from the date printed on the letter. Keep the envelope, courier slip or email header that proves when it reached you.

Section 62(2) and (3) allow an application for more time on reasonable grounds. The Commissioner General decides and serves notice of the decision. TRA's Objections and Appeals page adds two practical limits. Apply at least 7 days before the deadline expires, and expect no more than 30 extra days.

Those two limits come from TRA's page, not from the text of section 62 we read. Treat them as TRA practice and apply early.

Good reasons include illness of the key officer, documents held by a third party, or a decision served on the wrong address. Workload and a slow board meeting rarely persuade.

What must a notice of objection contain?

Section 62(4) to (6) set three rules. The objection must be in writing. It must state the grounds. It must come with the documents and information you intend to rely on, lodged at the same time as the notice.

The third rule matters most. Section 63(9) stops you relying at the appeal hearing on evidence you failed to give TRA when asked. A thin objection with a promise to "submit documents later" can lose the appeal before it starts.

ItemWhat to includeWhy
IdentityName, TIN, tax office, assessment number and date of serviceTRA must match the objection to the decision
Decision objected toCopy of the assessment or notice, with each disputed item listedSeparates disputed from undisputed tax
GroundsEach ground numbered, with the facts and the section relied onRequired by s.62(4)
EvidenceLedgers, contracts, invoices, bank statements, EFD records, reconciliationsRequired by s.62(5) and (6)
Undisputed taxYour computation of the tax you acceptFixes the deposit under s.62(7) and (10)
Deposit proofControl number and payment receipt, or the waiver applicationWithout it the objection is not admitted
SignatureSigned by the taxpayer or an authorised officerShows the objection is the taxpayer's own

Lodge it with the office that issued the decision. TRA's page names the Regional Office where you are registered, the Commissioner for Large Taxpayers, the Commissioner for Domestic Revenue, or the Commissioner for Customs and Excise. Get a stamped acknowledgment or an electronic receipt.

How much must you pay before TRA admits the objection?

Section 62(7) is the rule that catches most taxpayers. An objection to an assessment or a liability notice is not admitted unless, within 30 days of service, you pay the greater of:

Section 62(10) defines "tax not in dispute" as the tax that would be due if the assessment were amended as your objection asks. For duty or tax on imports, the whole amount assessed counts as not in dispute. Importers therefore pay in full before objecting.

Section 62(12) adds a further rule. If the Commissioner General reasonably believes you intend to leave the United Republic permanently, the deposit becomes the whole assessed tax.

Once the deposit is paid, section 62(9) suspends collection of the balance until the objection is finally determined. If the deposit is not paid in time, section 62(11) treats the assessment as final.

The Finance Act, 2025 changes added a deemed-admission rule. An objection to an assessment is treated as admitted on the date the filing and payment conditions are met, or the date a reduced amount is paid. Other objections are treated as admitted on the date they are served. You no longer wait for an admission letter. This is recorded as register item NEW-02-19.

Can TRA waive or reduce the objection deposit?

Yes. Section 62 lets the Commissioner General, for good reasons, waive the deposit or accept a lesser amount. TRA's Glance 2025/2026 says the application must be made within 15 days of receiving the tax decision. That is half the objection window, so the decision to ask must come early.

A waiver application should show three things:

Waivers are not granted often. Plan to pay the deposit and treat a waiver as a bonus.

The Court of Appeal changed one point in 2026. In Wilbert Basilius Kapinga v Commissioner General, TRA, Civil Appeal No. 145 of 2022, it held that a failure to decide a waiver application within the prescribed time is an omission that can be appealed to the Board. The FB Attorneys note of 9 February 2026 explains how the Court limited the earlier PanAfrican Energy decisions. Bowmans' note of 20 March 2026 reads the case the same way, and adds that a refusal of waiver itself remains non-appealable.

Worked example: a TZS 90 million assessment

A Dar es Salaam trading company receives an adjusted income tax assessment after an audit. The figures are illustrative only.

StepComputationAmount (TZS)
Tax assessedFrom the notice90,000,000
Tax not in disputeTax due if the objection succeeds in full30,000,000
One third of tax assessed90,000,000 ÷ 330,000,000
Deposit requiredGreater of the two lines above30,000,000
Balance suspended90,000,000 less 30,000,00060,000,000
Last day to object and pay30 days from service on 3 November 20263 December 2026
Last day to ask for a deposit waiver15 days from receipt, per TRA's Glance18 November 2026

Here the two tests give the same figure. Change the facts and they part company:

Suppose TRA later agrees to cut the assessment to TZS 50,000,000. The company owes a further TZS 20,000,000 on the final assessment. Interest on late tax runs at the statutory rate, compounded monthly (register NEW-02-08). The rate value for the third quarter of 2026 was 8.75% (register NEW-02-09). Confirm with TRA from which date interest is charged on the amount finally confirmed. Our guide to TRA penalties and interest shows the computation.

What happens after the objection is admitted?

Section 63 sets the process. The Commissioner General may ask for more evidence, then either amend the assessment or refuse to amend it.

  1. An evidence request must give a deadline of no more than 30 days from service, extendable by up to 7 days (s.63(7) and (8)).
  2. If TRA agrees with you, it serves a notice of final assessment or final decision (s.63(2)). That is the amended assessment.
  3. If TRA intends to amend only in part, or to refuse, it serves a notice with reasons (s.63(3)). Practitioners often call this the settlement proposal.
  4. You have 30 days from receipt of that notice to reply in writing (s.63(4)).
  5. TRA considers the reply and issues a final determination (s.63(5)).

The Finance Act, 2025 added a proviso at step 4. If you do not reply in time, the reasoned notice becomes the objection decision, and the appeal clock starts. Many taxpayers lose rights here by treating the notice as a negotiating letter.

A meeting with the auditors is often useful at this stage. Record what was agreed in writing, item by item, before the final determination is issued.

What if TRA does not decide within six months?

Section 63(10) requires the Commissioner General to determine the objection within six months of admission. Section 63(11) says what happens if TRA misses that limit: the assessment or decision is treated as confirmed, and you may appeal to the Board.

That is the reverse of what many taxpayers expect. Silence does not mean you have won on the Mainland. It means TRA's figure stands and the appeal route opens.

The Finance Act, 2025 added a second proviso. Where TRA served a reasoned notice before the six months ran out, that notice is treated as the objection decision. Diary the six-month date from the day the deposit is paid, and take advice in the final month.

When should you move to the Tax Revenue Appeals Board?

Once the final determination is served, or treated as made, the dispute leaves TRA. Under the Tax Revenue Appeals Act, Cap. 408 (TRA consolidation to 2019), the notice of appeal goes to the Commissioner General within 30 days, and the appeal is lodged with the Board within 45 days. The TRAB appeal procedure page names the forms as TRB.1 and TRB.2.

We do not repeat the appeal stage here. Our guide to appealing a TRA assessment to TRAB and TRAT covers it. Two points connect the stages:

Representation before the Board and the Tribunal is for an advocate or another representative the Act allows. Zatra routes every appeal to an advocate.

How does a tax objection work in Zanzibar?

Zanzibar has its own revenue authority and its own procedure for the taxes ZRA administers, such as Zanzibar VAT, hotel levy and stamp duty. The rules sit in the Tax Administration and Procedures Act No. 7 of 2009, consolidated to June 2025 by ZRA, mainly sections 21A to 21C. ZRA publishes a Notice of Objection to an Assessment form.

Income tax and other Union taxes in Zanzibar are administered by TRA, so those objections follow the Mainland Act. Check which authority issued the decision before choosing the route.

PointMainland (TRA)Zanzibar (ZRA)
LawTax Administration Act, Cap. 438, ss.61 to 64Tax Administration and Procedures Act No. 7 of 2009, ss.21A to 21C
Time to object30 days from service30 days from service (s.21A(1))
ExtensionOn reasonable grounds; TRA says up to 30 daysUp to 30 days on reasonable grounds (s.21A(6))
DepositGreater of undisputed tax or one thirdGreater of undisputed tax or one third (s.21A(8))
WaiverCommissioner General may waive or reduceCommissioner may reduce or waive (s.21A(10))
AdmissionDeemed on meeting the conditionsCommissioner admits or refuses; refusal appealable (s.21A(3) and (4))
Time to decideSix months from admission90 days from the notice of objection
If no decisionAssessment treated as confirmed; appeal to TRABCommissioner deemed to agree with the objection (s.21B)
Appeal bodyTRAB, then TRAT, then Court of Appeal on lawZanzibar Tax Appeals Board, then Tribunal, then Court of Appeal on law

The Zanzibar default favours the taxpayer. If ZRA does not decide within 90 days, the objection is treated as allowed. Under the Zanzibar Tax Appeals Act No. 1 of 2006, consolidated 2021, an appeal to the Board is lodged within 30 days of service of the objection decision, with written notice within 14 days. Our Zanzibar and Mainland VAT comparison explains which taxes ZRA collects.

What does a tax objection cost?

An objection to TRA carries no filing fee. The cost is the deposit, which is tax paid on account, not a charge. Appeal fees start at the Board. All figures below come from the Zatra government fee register.

ItemGovernment chargeRegister ID
Objection to a TRA tax decisionNo fee; deposit of the greater of undisputed tax or one third of tax assessedNEW-02-19
TRAB notice of appeal and statement of appealTZS 10,000 and TZS 100,000NEW-02-20
TRAB applications, such as extension of timeTZS 30,000NEW-02-20
TRAT notice of appeal and statement of appealTZS 30,000 and TZS 150,000NEW-02-21
TRAT extension of timeTZS 40,000NEW-02-21
Amicable settlement window at TRAB or TRAT90 days, extendable by up to 30 daysNEW-02-22

The TRAB fees come from the Second Schedule to the Tax Revenue Appeals Board Rules, 2018, GN 217 of 2018. The 2024 amendment, GN 539F, changed only rule 25 on execution. Zanzibar Board fees are not in our register; confirm them with the Zanzibar Board.

Government charges are paid at the official rate against the authority's control number. They are separate from Zatra's professional fee and from the advocate's fee.

Which mistakes most often sink an objection?

An unpaid assessment can also lead to recovery action. Our guide to TRA tax debt recovery and agency notices explains what TRA can do. Open disputes can also delay a tax clearance certificate.

What to do now

  1. Record service. Note the date and method by which the assessment reached you, and keep the proof.
  2. Diary the deadlines. Mark day 15 for any waiver request and day 30 for the objection and deposit.
  3. Split the assessment. List each adjustment as accepted or disputed, and compute the undisputed tax.
  4. Compute the deposit. Compare the undisputed tax with one third of the tax assessed and budget for the greater.
  5. Decide on a waiver. If cash is short, file a reasoned waiver application within 15 days with accounts and bank statements.
  6. Build the evidence file. Gather contracts, ledgers, reconciliations and EFD records, and attach them to the notice.
  7. Lodge and pay. File the written objection with the issuing office, pay against the control number, and keep both receipts.
  8. Answer every TRA notice. Reply to evidence requests and to any reasoned notice within the stated time.
  9. Prepare for appeal. If the decision goes against you, or six months pass, brief an advocate on the TRAB appeal at once.

Key dates and deadlines

EventTime limitSource
Application to waive or reduce the deposit15 days from receipt of the decisionTRA Glance 2025/2026, item 35
Application for extension to objectAt least 7 days before the deadline; extension up to 30 daysTAA s.62(2); TRA Objections page
Notice of objection30 days from service of the tax decisionTAA s.62(1); NEW-02-19
Deposit paymentWithin the same 30 daysTAA s.62(7); NEW-02-19
Evidence requested by TRAUp to 30 days, plus up to 7 days on extensionTAA s.63(7) and (8)
Reply to TRA's reasoned notice30 days from receiptTAA s.63(4)
TRA decision on objectionSix months from admissionTAA s.63(10)
Notice of appeal to TRAB; appeal lodged30 days; 45 days from the final determinationCap. 408; TRAB procedure page
Zanzibar: ZRA decision on objection90 days, or the objection is deemed allowedZanzibar Act No. 7 of 2009, s.21B

How Zatra helps

Zatra reads the assessment, separates accepted from disputed items, computes the deposit and prepares the notice of objection with its evidence file. Our TRA audit and dispute support runs the file from the audit letter to the final determination. Our tax and regulatory compliance service keeps the records that win objections. Where the issue is a future transaction, a TRA advance ruling can prevent the dispute.

Appeals to TRAB and TRAT, legal opinions, court applications, seizures and any prosecution go to an advocate, who represents you. Zatra prepares the file and coordinates. Zatra does not decide or guarantee any authority's outcome.

Government charges and the deposit are paid at the official rate against TRA's or the Board's control number. They are separate from Zatra's professional fee, which we quote in writing before work starts. To begin, contact Zatra with the assessment and the date it was served.

Sources and status

Accurate as at 7 November 2026.

Figures to confirm before you act

This article is general information based on official sources available at the date of publication. It is not legal, tax or financial advice. Laws and notices change. Verify with the issuing authority or consult Zatra before acting.

Frequently asked questions

Can I object to only part of a TRA assessment?

Yes, and you usually should. List the items you accept and pay that tax. The undisputed part counts toward the deposit, and conceding weak items makes the remaining grounds more credible to the Commissioner General and later to the Board.

Does objecting stop TRA from collecting the tax?

Only the balance, and only after the deposit is paid. The deposit itself must be paid within 30 days. Until it is paid, the whole assessment remains collectable, and agency notices to your bank remain possible.

Can I object to penalties and interest as well as the tax?

You can challenge how they were computed. A separate route exists for asking TRA to remit interest and penalties under section 81 of the Act. Remission is discretionary, so treat it as a separate request rather than a ground of objection.

Do I get the deposit back if the objection succeeds?

Any amount paid above the final tax is an overpayment. It is normally credited against other tax liabilities or refunded through TRA's refund process. Ask TRA to state the treatment in the final determination notice.

Can a tax consultant lodge the objection on my behalf?

Yes. A licensed tax consultant or another authorised person can prepare and lodge it, signed with the taxpayer's authority. Representation at the Board and Tribunal follows the Tax Revenue Appeals Act, and Zatra uses an advocate there.

What if the assessment was served on an old address?

Write to TRA at once, stating when you received it and attaching the proof. Ask for confirmation that the 30 days run from actual receipt. If TRA disagrees, apply for an extension of time on that ground before the window closes.

Is a self-assessed return open to objection?

A self-assessment is treated as a tax decision made on the return's due date. Errors in your own return are normally fixed by correcting the return rather than objecting. Objection fits when TRA later adjusts that return.

Does a Zanzibar company object to ZRA or TRA?

It depends on the tax. Zanzibar VAT, hotel levy and other ZRA taxes go to ZRA under the 2009 Act. Income tax assessed by TRA in Zanzibar follows the Mainland Tax Administration Act and its objection rules.

Sources & regulators

Verify before filing: Rates, forms and thresholds move by Finance Act, Government Notice and portal revision. Confirm the live schedule on the mandate-holder portal before you budget or submit. Law-firm alerts and Big Four notes are discovery only.

Brief the desk

This Insights page is orientation. TRA Tax Audit and Dispute Support in Tanzania is the commercial desk for the same facts. Zatra’s fee stays on its own line, separate from government, bank and regulator charges. Approvals are not guaranteed.

Book a 20-minute file check Talk to Zatra

+255 788 466 212 · [email protected] · WhatsApp +255 747 912 965

Disclaimer

This article is informational orientation. It is not legal, tax or investment advice and not a government decision. Tanzanian instruments move by Act, Government Notice, Finance Act and portal revision. If a sentence here disagrees with the live mandate-holder, the mandate-holder wins. Zatra Consultants Limited does not issue licences, permits, tax clearances or approvals, and gives no assurance of any regulatory or banking outcome. Professional fees are published only on /pricing/.

Office Line +255 788 466 212
Ask Senior Desk on WhatsApp